Subject: File No. S7-25-99
From: Evans M. Harrell

July 25, 2004


There is no way a stock broker-dealer can give unbiased, non-self-serving counsel and advice to clients. By no stretch of the imagination can any such be deemed an "investment advisor".

I base this on some 50 years of investing experience handling my own affairs and having to deal with brokers and their ilk. I have tested them many times and have proven to my satisfaction that they cannot be trusted to render impartial, fair, un-biased advice. They must cause their clients to trade as their only source of income is their commissions.

In other words, broker-dealers, as defined by the SEC, should NOT be exempt.


Evans M. Harrell
551 N. St., Mary's Ln., NW
Marietta, GA 30064-1411
FAX: 770-795-4545
Cell: 678-414-8894